We have set up this hub to support advisers with their Consumer Duty journey. We hope it will help you better understand our role in the new framework, and to assist you with incorporating those elements into your own processes for the benefit of your business and your clients. We will continue to add to the resources available here, so please keep checking back for new information.
The FCA’s Consumer Duty establishes higher and clearer standards of consumer protection across financial services, requiring firms to prioritise customer needs at every stage. The Duty is now fully embedded within financial services, but ensuring good customer outcomes is an ongoing process. The new framework focuses on four key outcomes:
Products and servicesEnsuring products are designed to meet the needs of their intended target market. |
Consumer understandingProviding clear and accessible information to help clients make informed decisions. |
Price and valueEnsuring products and services offer fair value. |
Consumer supportDelivering a high standard of service and assistance throughout the client journey. |
Consumer Duty applies to both manufacturers (TAM) and distributors (advisers) of financial services and products. As part of our commitment to ongoing support, we work closely with advisers to ensure they can meet their responsibilities under the Duty—particularly when assisting clients with characteristics of vulnerability.
Strong communication and collaboration between TAM and advisers is essential to ensuring that every client receives the best possible outcomes. This means:
- Providing advisers with clear, up-to-date information about TAM products and services.
- Working together to identify and support vulnerable clients who may need additional guidance or tailored communication.
- Regularly reviewing our processes to ensure they align with the highest standards of consumer protection.
Below you will find links to tools and information we have collated to support your compliance with the regulations. We will continue to add to the supporting information here, so please keep checking back to see what's new.
We have undertaken price and value assessments across our service range, all of which can be accessed below and are a key step in enabling you to work out all aspects of the value chain.
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TAM Fair Value Assessment |
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TAM Active Target Market Assessment |
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TAM Enhanced Passive Target Market Assessment |
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TAM Sustainable World Target Market Assessment |
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TAM Sharia Target Market Assessment |
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| TAM Income Target Market Assessment |  |
There were five key milestones for the implementation of the Consumer Duty rules, with a sixth milestone focused on adherence, ensuring continuous compliance and development moving forward.
1 |
2 |
3 |
4 |
5 |
27 July 2022 |
31 October 2022 |
30 April 2023 |
31 July 2023 |
31 July 2024 |
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Final rules and guidance
published.
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Firms’ boards (or equivalent
management body) should have
agreed their implementation
plans and be able to evidence
they have scrutinised and
challenged the plans to ensure
they are deliverable and robust
to meet the new standards.
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Manufacturers should have completed
all the reviews necessary to meet the
outcome rules for their existing open
products and services so they can
share with distributors to meet their
obligations under the Duty, and
identify where changes need to
be made.
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Implementation deadline for new
and existing products or services
that are open to sale or renewal.
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Implementation deadline for
closed products or services.
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As part of our continuous adherence to the Consumer Duty, TAM places a high priority on the ongoing review and monitoring of products to ensure they continue to meet the needs of all clients. We recognize the importance of advisers regularly reviewing the suitability of TAM’s products for their clients, particularly in terms of risk profiles and any characteristics of vulnerability.
Advisers must ensure that suitability assessments and risk evaluations are continuously updated, reflecting any changes in their clients' circumstances. This is particularly important for clients with characteristics of vulnerability. Advisers should communicate with TAM if any adjustments are needed to better support clients, especially those who may be more vulnerable. This collaboration ensures that TAM, in its capacity as a Discretionary Fund Manager (DFM), can positively influence the client experience by adapting our approach where necessary.
In line with our governance practices, we have embedded Consumer Duty compliance as a static agenda item for regular review by the TAM Board. This ensures that Consumer Duty remains a central focus in our ongoing operations and product offerings. The board will review product performance, the suitability of products, and any necessary changes to ensure they remain in the best interest of all clients, particularly those with vulnerable characteristics.
Through regular communication and feedback, advisers help us meet the Consumer Duty by ensuring the fair treatment of all clients, including those who may be more vulnerable. By working together, we can ensure that our clients are receiving the best possible outcomes while adhering to regulatory requirements.
This is not a “one and done” exercise, we endeavour to monitor and develop our review of all requirements under the Consumer Duty regime and continue to seek ways to further improve the consumer experience. Co-operation and information sharing between firms across the distribution chain is a key area of focus for the FCA and a fundamental element in achieving the objectives of the Consumer Duty. We look forward to working together on this journey and sharing any relevant information to ensure we are working toward a shared goal of acting to deliver good consumer outcomes.
Please get in touch with our UK Business Development Manager, David Terry, if you have any questions regarding our approach to the Consumer Duty and how we can support you.
T: +44 (0) 7585 070 116 | E: david.terry@tamassetmanagement.com
